ML020520682

Proposed Change to ISTS NUREGs 1430, 1431, 1432, 1433 & 1434, Removing Hydrogen Recombiner & Hydrogen & Oxygen Analyzer Tech Specs from ISTS

ML020520682
Person / Time
Issue date:	02/21/2002
From:	Beckner W D NRC/NRR/DRIP/RORP
To:	Pietrangelo A R Nuclear Energy Institute
Benner, E J, NRC/NRR/DRIP/REXB
References
Download: ML020520682 (37)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION 0 gWASHINGTON, D.C. 20555-0001 February 21, 2002 Mr. Tony Pietrangelo, Director Risk and Performance Based Regulation Nuclear Energy Institute 1776 I Street, N. W. Suite 400 Washington, DC 20006-3708

Dear Mr. Pietrangelo:

Enclosed is a proposed change to the Improved Standard Technical Specification (ISTS) NUREGs 1430, 1431, 1432, 1433 and 1434: NRC traveler number TSB-026. The proposed change removes hydrogen recombiner, and hydrogen and oxygen analyzer technical specifications from the ISTS to be consistent with proposed changes to 10 CFR 50.44, Combustible Gas Control.

The NRC is proposing to amend 10 CFR 40.44 to eliminate the requirement for hydrogen recombiners and to allow hydrogen and oxygen monitors to be commercial grade instead of safety grade. These changes stem from the Commission's ongoing effort to risk-inform its regulations.

The staff will issue the proposed rule for public comment in the near future and intends to issue a model safety evaluation including proposed changes to the ISTS NUREGs for public comment at the same time. In accordance with your draft white paper on the process for changing of improved standard technical specification NUREGs, the NRC is forwarding this change to the Technical Specification Task Force (TSTF) for industry review. Please contact me at (301) 415-1161 or e-mail wdb(Dnrc.qov if you have any questions or need further information on these proposed changes.

Sincerely, William D. Beckner, Program Director Operating Reactor Improvements Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation

Enclosure:

As stated cc: M. Schoppman, NEI J. Arbuckle, BWROG D. Bice, CEOG N. Clarkson, BWOG S. Wideman, WOG D. Hoffman, EXCEL February 21, 2002 Mr. Tony Pietrangelo, Director Risk and Performance Based Regulation Nuclear Energy Institute 1776 1 Street, N. W. Suite 400 Washington, DC 20006-3708

Dear Mr. Pietrangelo:

Enclosed is a proposed change to the Improved Standard Technical Specification (ISTS) NUREGs 1430, 1431, 1432, 1433 and 1434: NRC traveler number TSB-026. The proposed change removes hydrogen recombiner, and hydrogen and oxygen analyzer technical specifications from the ISTS to be consistent with proposed changes to 10 CFR 50.44, Combustible Gas Control.

The NRC is proposing to amend 10 CFR 40.44 to eliminate the requirement for hydrogen recombiners and to allow hydrogen and oxygen monitors to be commercial grade instead of safety grade. These changes stem from the Commission's ongoing effort to risk-inform its regulations.

The staff will issue the proposed rule for public comment in the near future and intends to issue a model safety evaluation including proposed changes to the ISTS NUREGs for public comment at the same time. In accordance with your draft white paper on the process for changing of improved standard technical specification NUREGs, the NRC is forwarding this change to the Technical Specification Task Force (TSTF) for industry review. Please contact me at (301) 415-1161 or e-mail wdb(,nrc.qov if you have any questions or need further information on these proposed changes.

Sincerely, /RA/ William D. Beckner, Program Director Operating Reactor Improvements Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation

Enclosure:

As stated DISTRIBUTION PUBLIC cc: M. Schoppman, NEI DMatthews/FGillespie J. Arbuckle, BWROG WBeckner D. Bice, CEOG RDennig N. Clarkson, BWOG EBenner S. Wideman, WOG TSS R/F D. Hoffman, EXCEL TSB-026 (LHilI)

• See previous concurrence DOCUMENT NAME:G:\RTSB\TSTF INFO\Owners Group Correspondence\tsb-026 proposed change transmittal letter.wpd To receive a copy of this document, Indicate In the box: "C" = Copy without attach t closure "E" = Copy with attachment/enclosure "N" = No copy OFFICE TSS:IMA I TSS:R I TSS: -Jj) RORP:PD I ,l NAME LHiII* EBenner* RDeniq / WBeckner [ijb DATE 02/14/02 02/14/02 02/ _/02 02 /102 OFFICIAL RECORD COPY DR~AFT 7Zr-A WC~ CH ,4A&~T 5 -L)6eO5z2 '5ý-5:5&CL4-2250 Hydrogen Recombiners (Atmospheric, Subatmospheric, Ice Condenser, and Dual) 3.6.8 CONTAINMENT SYSTEMS Hydrogen Recombiners (Atmospheric, Subatmospheric, Ice Condenser, and Dual) (if permanently installed)

LCO 3.6.8 Two hydrogen recombiners shall be OPERABLE.1 and 2.A. One hydrogen recombiner inoperable.

B. [ Two hydrogen recombiners inoperable.

C. Required Actioy/nd associated Cpfnpletion Time not mA.Reore hydrog reco biner to PERABLE status.to o Restore one hydrogen recombiner to OPERABLE status.30 days 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter Rev. 2, 04/30/01 Enclosure 3.6J STS 3.6.8-1 JtRA F-7 Hydrogen Recombiners (Atmospheric, Subatmospheric, Ice Condenser, and Dual) Rev. 2, 04/30/01 WOG STS 3.6.8- 2 PAM Instrumentation 3.3.3 3.3 INSTRUMENTATION 3.3.3 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3 APPLICABILITY:

The PAM instrumentation for each Function in Table 3.3.3-1 shall be OPERABLE.

MODES 1, 2, and 3.-NOTES 1 LCO 3.0.4 is not applicable.

2. Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required channel 30 days with one required to OPERABLE status. channel inoperable.

B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A not Specification 5.6.7. met. .-- ------C.1 Restore one channel to 7 days E -1 OPERABLE status. Not a icablt hy ogen itor ann One or more Functions with two required channels inoperable.

D o hydrogen nito channels~

perab.Restore, ydrogen mpoir ochannel to PERABLE us.725"---ýr s Rev. 2, 04/30/01 ACTIONSýe~e7 3.3.3- 1 WOG STS, I I I 0Z4 ýT 0121FT PAM Instrumentation

3.3.3 Table

3.3.3-1 (page 1 of 1) Post Accident Monitoring Instrumentation CONDITION REFERENCED FROM FUNCTION REQUIRED CHANNELS REQUIRED ACTION E.1 1. Power Range Neutron Flux 2 F 2. Source Range Neutron Flux 2 F 3. Reactor Coolant System (RCS) Hot Leg 2 per loop F Temperature

4. RCS Cold Leg Temperature 2 per loop F 5. RCS Pressure (Wide Range) 2 F 6. Reactor Vessel Water Level 2 G 7. Containment Sump Water Level (Wide Range) 2 F 8. Containment Pressure (Wide Range) 2 F 9. Penetration Flow Path Containment Isolation Valve 2 per peneorin flow F Position pathlaiatl

10. Containment Area Radiation (High Range) 2 G 12. Pressurizer Level 2 F 13. Steam Generator Water Level (Wide Range) 2 per steam generator F 14. Condensate Storage Tank Level 2 F 15. Core Exit Temperature

-Quadrant [1] 2(c) F 16. Core Exit Temperature

-Quadrant [2] 2 (c) F 17. Core Exit Temperature

-Quadrant [3] 2 (c) F 18. Core Exit Temperature

-Quadrant [4] 2(c) F 19. Auxiliary Feedwater Flow 2 F (a) Not required for isolation valves whose associated penetration is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured. (b) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel. (c) A channel consists of two core exit thermocouples (CETs). -REVIEWER'S NOTE Table 3.3.3-1 shall be amended for each unit as necessary to list: 1. All Regulatory Guide 1.97, Type A instruments and 2. All Regulatory Guide 1.97, Category I, non-Type A instruments in accordance with the unit's Regulatory Guide 1.97, Safety Evaluation Report. S..........................................

o ....................................................

Rev. 2, 04/30/01 3.3.3-3 WOG STS PAM Instrumentation B 3.3.3 BASES LCO (continued) for use by operators in determining the need to invoke site emergency plans. Containment radiation level is used to determine if a high energy line break (HELB) has occurred, and whether the event is inside or outside of containment.

11 oen Monitprst Hydr n Monitors are ovided to detect h ydrogen Dt-a'-rotential for cainment Sbreach from yrgnepoi.hsvrable'so mportantij v rifying te adequacy of gatin actions 12. Pressurizer Level Pressurizer Level is used to determine whether to terminate SI, if still in progress, or to reinitiate SI if it has been stopped. Knowledge of pressurizer water level is also used to verify the unit conditions necessary to establish natural circulation in the RCS and to verify that the unit is maintained in a safe shutdown condition.

13. Steam Generator Water Level (Wide Range) SG Water Level is provided to monitor operation of decay heat removal via the SGs. The Category I indication of SG level is the extended startup range level instrumentation.

The extended startup range level covers a span of > 6 inches to _< 394 inches above the lower tubesheet.

The measured differential pressure is displayed in inches of water at 68 0 F. Temperature compensation of this indication is performed manually by the operator.

Redundant monitoring capability is provided by two trains of instrumentation.

The uncompensated level signal is input to the unit computer, a control room indicator, and the Emergency Feedwater Control System. SG Water Level (Wide Range) is used to:

• identify the faulted SG following a tube rupture, verify that the intact SGs are an adequate heat sink for the reactor, Rev. 2, 04/30/01 WOG STS B 3.3.3 -8 06?4Fr PAM Instrumentation B 3.3.3 BASES ACTIONS (continued) a 0 F II pplied to the PAM instrumentation.

Therefore, requiring restoration of ne inoperable channel of the Function limits the risk that the PAM "unction will be in a degraded condition should an accident occur C jemodifiedbj a Nole that excludes hydrogen monitor Condition E applies when the Required Action and associated Completion Time of Condition C or D are not met. Required Action E.1 requires entering the appropriate Condition referenced in Table 3.3.3-1 for the channel immediately.

The applicable Condition referenced in the Table is Function dependent.

Each time an inoperable channel has not met any Required Action of Condition C or D, and the associated Completion Time has expired, Condition E is entered for that channel and provides for transfer to the appropriate subsequent Condition.

F.1 and F.2 If the Required Action and associated Completion Time of Conditions C or D are not met and Table 3.3.3-1 directs entry into Condition F, the unit must be brought to a MODE where the requirements of this LCO do not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.Rev. 2, 04/30/01 B 3.3.3 -13 WOG STS

-2Primary Containment Hydrogen Recombiners 3.6.3.1 SYSTEMS 3.6.3.1\ Primary Containment Hydrogen Recombiners (if permanently installed)

LCO 3.6.3.'Two primary containment hydrogen recombiners shall be OPI MODES 1 and 2.ACTIONS A. One primary containment hydrogen recombiner inoperable.

B. [ Two primary containment hydrogen recombiners inoperable.

maintained.

AND B.2 Restore one primary containment hydrogen recombiner to OPERABLE status.30 days 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> AND One per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter 7 days ]Rev. 2, 04/30/01 STS 3.6.3.1-1 Primary Containment Hydrogen Recombiners 3.6.3.1 Ac) i Rev. 2, 04/30/01 BWPJ6 STS 3.6.3.1-2 0634PZ PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 APPLICABILITY:

The PAM instrumentation for each Function in Table 3.3.3. 1-1 shall be OPERABLE.

MODES 1 and 2.ACTIONS -NOTES 1. LCO 3.0.4 is not applicable.

2. Separate Condition entry is allowed for each Function.7 Rev. 2, 04/30/01 I I 3.3.3.1-1 BWR/6 STS PAM Instrumentation 3.3.3.1 Table 3.3.3.1-1 (page 1 of 1) Post Accident Monitoring Instrumentation CONDITIONS REFERENCED.

FROM REQUIRED REQUIRED FUNCTION CHANNELS ACTION E.1 Reactor Steam Dome Pressure Reactor Vessel Water Level Suppression Pool Water Level Drywell Pressure Primary Containment Area Radiation Drywell Sump Level Drywell Drain Sump Level Penetration Flow Path PCIV Position 2 2 2 2 2 2 2 2 per pene r"ion flow pathla'c) 2 Primary Containment Pressure [Relief Valve Discharge Location]

Suppression Pool Water Temperature 2 2(c)F F F F [G] F] F] F F F (a) Not required for isolation valves whose associated penetration flow path is isolated by at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured. (b) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel. (c) Monitoring each [relief valve discharge location).

-REVIEWER'S NOTE Table 3.3.3.1-1 shall be amended for each plant as necessary to list: 1. All Regulatory Guide 1.97, Type A instruments and 2. All Regulatory Guide 1.97, Category 1, non-Type A instruments specified in the plant's Regulatory Guide 1.97, Safety Evaluation Report.Rev. 2, 04/30/01 1. 2. 3. 4. 5. [6. [7. 8.11. 12. 13.6kkk BWR/6 STS 3.3.3.1-3 PAM Instrumentation B 3.3.3.1 BASES LCO (continued) position indication in the control room to be OPERABLE for each active PCIV in a containment penetration flow path, i.e., two total channels of PCIV position indication for a penetration flow path with two active valves. For containment penetrations with only one active PCIV having control room indication, Note (b) requires a single channel of valve position indication .to be OPERABLE.

This is sufficient to verify redundantly the isolation status of each isolable penetration via indicated status of the active valve, as applicable, and prior knowledge of passive valve or system boundary status. If a penetration is isolated, position indication for the PCIV(s) in the associated penetration flow path is not needed to determine status. Therefore, the position indication for valves in an isolated penetration is not required to be OPERABLE.

Each penetration is treated separately and each penetration flow path is considered a separate function.

Therefore, separate Condition entry is allowed for each inoperable penetration flow path. [For this plant, the PCIV position PAM instrumentation consists of the following:

] 9. Wide Range Neutron Flux Wide range neutron flux is a Category I variable provided to verify reactor shutdown.

[For this plant, wide range neutron flux PAM instrumentation consists of the following:

] 1 lDrvLwell-and Containment Hydrogen and 09va'Ky~en rywell dcont ment hyd gen and o gen anal s are CatIeg F instr ents pr ided to d ct high h ogen or o gen concent oi-on ietio_. t cers a ona nt bre~ach. ./is ariable" also imp ant in veri ing the a uacy of miti ing actio [F, this Plan e d and contai ent hydrogen and oxy ýanalyz~ers AM instrumentation consists of the following:

12. Primary Containment Pressure Primary containment pressure is a Category I variable provided to verify RCS and containment integrity and to verify the effectiveness of ECCS actions taken to prevent containment breach. Two wide range primary containment pressure signals are transmitted from separate pressure Rev. 2, 04/30/01 B 3.3.3.1 -5 BWR./6 STS PAM Instrumentation B 3.3.3.1 BASES ACTIONS (continued)

C..1 When one or more Functions have two required channels that are inoperable (i.e., two channels inoperable in the same Function), one channel in the Function should be restored to OPERABLE status within 7 days. The Completion Time of 7 days is based on the relatively low probability of an event requiring PAM instrument operation and the availability of alternate means to obtain the required information.

Continuous operation with two required channels inoperable in a Function is not acceptable because the alternate indications may not fully meet all performance qualification requirements applied to the PAM instrumentation.

Therefore, requiring restoration of one inoperable channel of the Function limits the risk that the PAM Function will be in Sdegraded condition should : an accident gccur..lCondition C is moplfed by *that excludes hydrogen monitor channels.

ConcýUon D,/rovides r' Require tions for two ' operable h hgen onitor S cha eIs. 6~W en two hyd en monitor c nnels a inoperabl one hydroge onittor ch nel must be eored to ERABLE Latus within 7 ours. The 72 ur Completio ime1i asonable, bed on the b up ca I ity of the Pos cciden ampling S em to monito e hydrog centration for aluti of core dam e and to pr .ie inform Wn for operator djisions.

so, it is unli y that a LO that wouWcause core dama would o cur during this time. E.1 This Required Action directs entry into the appropriate Condition referenced in Table 3.3.3.1-1.

The applicable Condition referenced in the Table is Function dependent.

Each time an inoperable channel has not met any Required Action of Condition C or D, as applicable, and the associated Completion Time has expired, Condition E is entered for that channel and provides for transfer to the appropriate subsequent Condition.

F._1 For the majority of Functions in Table 3.3.3.1-1, if any Required Action and associated Completion Time of Condition C or D is not met, the plant Rev. 2, 04/30/01 B 3.3.3.1 -8 BWPJ6 STS oe4F'r- Primary Containment Hydrogen Recombiners 3.6.3.1 3. CONTAINMENT SYSTEMS 3.6.3. Primary Containment Hydrogen Recombiners (if permanently installed)

LCO 3.6.3. Two primary containment hydrogen recombiners shall be C APPLICABILITY:

MODES and 2./ ACTIONS/CONDITION REQUIRED ACTION COMPLETION TIME A. Oneprimary

.1 containment hydrogen -NOTE recombiner inoperable.

LCO 3.0.4 is, not S LCO3.4 is not applicable.

estore prima 30 days tainment drogen \ re biner OPERABLE statu B. [Two primary B.1 Verify y dministrative 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> containment hydrogen me s that he hydrogen recombiners inoperable.

trol functi is AND aintained.

Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter A B.2 Restore one primary 7 days] containment hydrogen recombiner to OPERABLE status. C. Required Action nd C.1 Be in MODE 3. 12 hou associated Co pletion Time not me.II BW STS3...-IRe.2040/

Rev. 2, 0/3/3.6.3.1-1 Primary Containment Hydrogen Recombiners 3.6.3.1 oeld e--ec Rev. 2, 04/30/01 3.6.3.1-2 BW R/4 STS t(219/PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 APPLICABILITY:

The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE.

MODES 1 and 2.ACTIONS -NOTES 1. LCO 3.0.4 is not applicable.

2. Separate Condition entry is allowed for each Function.Rev. 2, 04/30/01 I I c6eýe, BWR/4 STS 3.3.3.1-1 PAM Instrumentation 3.3.3.1 Table 3.3.3.1-1 (page 1 of 1) Post Accident Monitoring Instrumentation CONDITIONS REFERENCED REQUIRED FROM REQUIRED FUNCTION CHANNELS ACTION E.1 1. Reactor Steam Dome Pressure 2 F 2. Reactor Vessel Water Level 2 F 3. Suppression Pool Water Level 2 F 4. Drywell Pressure 2 F 5. Primary Containment Area Radiation 2 [G] [ 6. Drywell Sump Level 2 F] [ 7. Drywell Drain Sump Level 2 F] 8. Penetration Flow Path PCIV Position 2 per penelrion flow F path 9. Wide Range Neutron Flux 2 F 10. Drywelt7&

02 Analyzer W 2 F 11. ContainmentS&

02 Analyzer 2 F 12. Primary Containment Pressure 2 F 13. [Relief Valve Discharge Location]

Suppression Pool 2(c) F Water Temperature (a) Not required for isolation valves whose associated penetration flow path is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured. (b) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel. (c) Monitoring each [relief valve discharge location].

-REVIEWER'S NOTE Table 3.3.3.1-1 shall be amended for each plant as necessary to list: 1. All Regulatory Guide 1.97, Type A instruments and 2. All Regulatory Guide 1.97, Category 1, non-Type A instruments specified in the plant's Regulatory Guide 1.97, Safety Evaluation Report.Rev. 2, 04/30/01 3.3.3.1-3 BWRJ4 STS PAM Instrumentation B 3.3.3.1 BASES LCO (continued) indication to be OPERABLE.

This is sufficient to redundantly verify the isolation status of each isolable penetration via indicated status of the active valve, as applicable, and prior knowledge of passive valve or. system boundary status. If a penetration flow path is isolated, position indication for the PCIV(s) in the associated penetration flow path is not needed to determine status. Therefore, the position indication for valves in an isolated penetration flow path is not required to be OPERABLE.

Each penetration is treated separately and each penetration flow path is considered a separate function.

Therefore, separate Condition entry is allowed for each inoperable penetration flow path. [For this plant, the PCIV position PAM instrumentation consists of the following:

] 9. Wide Range Neutron Flux Wide range neutron flux is a Category I variable provided to verify reactor shutdown.

[For this plant, the wide range neutron flux PAM instrumentation consists of the following:]

10. 11. Drywell and Containmen txygen Analyzers Drywell and containmen t9 oxygen analyzers are Category I instruments provided to detect high xygen concentration conditions that represent a potential for containment breach. This variable is also important in verifying the adequacy of mitigating actions.

[For this plant, the drywell and containmen tf xygen analyzers PAM instrumentation consists of the following:]

12. Primary Containment Pressure Primary containment pressure is a Category I variable provided to verify RCS and containment integrity and to verify the effectiveness of ECCS actions taken to prevent containment breach. Two wide range primary containment pressure signals are transmitted from separate pressure transmitters and are continuously recorded and displayed on two control room recorders.

These recorders are the primary indication used by the operator during an accident.

Therefore, the PAM Specification deals specifically with this portion of the instrument channel.Rev. 2, 04/30/01 BWPJ4 STS B 3.3.3.1 -5 PAM Instrumentation B 3.3.3.1 BASES ACTIONS (continued)

C..1 When one or more Functions have two required channels that are inoperable (i.e., two channels inoperable in the same Function), one channel in the Function should be restored to OPERABLE status within 7 days. The Completion Time of 7 days is based on the relatively low probability of an event requiring PAM instrument operation and the availability of alternate means to obtain the required information.

Continuous operation with two required channels inoperable in a Function is not acceptable because the alternate indications may not fully meet all performance qualification requirements applied to the PAM instrumentation.

Therefore, requiring restoration of one inoperable channel of the Function limits the risk that the PAM Function il hp in ..degraded condition should aacietccur C is modied by Sa No pLhat expGl~es hydr'en-monit cwhannels,/Condition D l~,vides -.,ropriat e'equired Adions foriId inoperapl hydrogen h'itor W ln two hydr en monto anel ae'perable, one brogen onitor ch el must b estored to 0 RABLE status hin 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> el a-The 72 r Compl n Time is ba don the low pr ability of th occur nce of a CA thatwoul generate hydro in amou capable of ceedin e flammabilit it;thelengtho ime after t event that erator ionwouldbe quiredtopreven ydrogen a iumulation m, excee " gthislimit; the availability e hydropr recombin the Hyd ogen Purge tem, and the Post Accident Sampling Syst E.1 This Required Action directs entry into the appropriate Condition referenced in Table 3.3.3.1-1.

The applicable Condition referenced in the Table is Function dependent.

Each time an inoperable channel has not met any Required Action of Condition C or D, as applicable, and the associated Completion Time has expired, Condition E is entered for that channel and provides for transfer to the appropriate subsequent Condition.

F..1 For the majority of Functions in Table 3.3.3.1-1, if any Required Action and associated Completion Time of Condition C or D are not met, the Rev. 2, 04/30/01 BWRJ4 STS B 3.3.3.1 -8

-OL0AePC 4 A160CIAl 0646!ý Hydrogen Recombiners (Atmospheric and Dual) 3.6.8 3.6 ONTAINMENT SYSTEMS 3.6.8 ydrogen Recombiners (Atmospheric and Dual) (if permanently installed)

LCO 3.6.8 [Two] hydrogen recombiners shall be OPERABLE.

APPLICABILITY:

ODES 1 and 2. ACTIONS 7 CONDITION REQUIRED ACTION COMPLETION TIME A. One hydrogen .,- recombiner inoperable.

-NOTE LCO 3.0.4 is not -\~~applicable.--------

estore hydrog 30 days r mbiner to/OPERABLE B. [Two hydrogen B.1 Verify bdministrative 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> recombiners inoperable, means t the hydrogen contr fun ion is AND mai tamned. Once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter B. Restore one hydrogen 7 days] recombiner to OPERABL status. C. Required Action and C.1 Be in MODE 3. ours associated Completi Time not met. /t\CEOG ST Rev. \2,04130 3.6.8- 1 DR-AF T Hydrogen Recombiners (Atmospheric and Dual) 3.6.8 Rev. 2, 04/30/01 CEOG STS 3.6.8- 2 PAM Instrumentation (Analog) 3.3.11 3.3 INSTRUMENTATION 3.3.11 Post Accident Monitoring (PAM) Instrumentation (Analog)LCO 3.3.11 APPLICABILITY:

The PAM instrumentation for each Function in Table 3.3.11-1 shall be OPERABLE.

MODES 1, 2, and 3.ACTIONS -NOTES 1. LCO 3.0.4 is not applicable.

2. Separate Condition entry is allowed for each Function.Rev. 2, 04/30/01 a~eýe I I CEOG STS 3.3.11- 1 PAM Instrumentation (Analog) 3.3.11 Table 3.3.11-1 (page 1 of 1) Post Accident Monitoring Instrumentation CONDITIONS REFERENCED FROM REQUIRED FUNCTION REQUIRED CHANNELS ACTION E.1 1. [Logarithmic]

Neutron Flux 2 2. Reactor Coolant System Hot Leg Temperature 2 per loop 3. Reactor Coolant System Cold Leg Temperature 2 per loop 4. Reactor Coolant System Pressure (wide range) 2 5. Reactor Vessel Water Level 2 6. Containment Sump Water Level (wide range) 2 7. Containment Pressure (wide range) 2 8. Penetration Flow Path Containment Isolation 2 per penetraion flow Valve Position path~a)(l

9. Containment Area Radiation (high range) 2 l(i2 tain'me yd -n Monito 2 11. Pressurizer Level 2 12. Steam Generator Water Level (wide range) 2 per steam generator

13. Condensate Storage Tank Level 2 14. Core Exit Temperature

-Quadrant [1] 2 (c) 15. Core Exit Temperature

-Quadrant [2] 2(P) 16. Core Exit Temperature

-Quadrant [3] 2(c) 17. Core Exit Temperature

-Quadrant [4] 2(c) 18. Auxiliary Feedwater Flow 2 F F F F [Gq F F F [G] F ' F F F F F F F (a) Not required for isolation valves whose associated penetration is isolated by at least one closed and de activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured. (b) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel. (c) A channel consists of two or more core exit thermocouples. -REVIEWER'S NOTE Table 3.3.11-1 shall be amended for each unit as necessary to list: 1. All Regulatory Guide 1,97, Type A instruments and 2. All Regulatory Guide 1.97, Category I, non-Type A instruments specified in the unit's Regulatory Guide 1.97, Safety Evaluation Report.Rev. 2, 04/30/01 CEOG STS 3.3.11- 3 PAM Instrumentation (Digital) 3.3.11 3.3 INSTRUMENTATION 3.3.11 Post Accident Monitoring (PAM) Instrumentation (Digital)LCO 3.3.11 APPLICABILITY:

The PAM instrumentation for each Function in Table 3.3.11-1 shall be OPERABLE.

MODES 1, 2, and 3. During movement of [recently]

irradiated fuel assemblies.

ACTIONS -NOTES 1. LCO 3.0.4 not applicable.

2. Separate Condition entry is allowed for each Function.Rev. 2, 04/30/01 I I CEOG STS 3.3.11- 1 PAM Instrumentation (Digital) 3.3.11 Table 3.3.11-1 (page 1 of 1) Post Accident Monitoring Instrumentation CONDITIONS REFERENCED FROM FUNCTION REQUIRED CHANNELS REQUIRED ACTION E.1 1. [Wide Range] Neutron Flux 2 F 2. Reactor Coolant System Hot Leg Temperature 2 per loop F 3. Reactor Coolant System Cold Leg Temperature 2 per loop F 4. Reactor Coolant System Pressure (wide range) 2 F 5. Reactor Vessel Water Level 2 [G] 6. Containment Sump Water Level (wide range) 2 F 7. Containment Pressure (wide range) 2 F 8. Penetration Flow Path Containment Isolation Valve 2 per penetr ion flow F Position pathýa(,)( 9. Containment Area Radiation (high range) 2 [G] C:.-oý~ainment Moonit 11. Pressurizer Level 2 F 12. Steam Generator Water Level (wide range) 2 per steam generator F 13. Condensate Storage Tank Level 2 F 14. Core Exit Temperature

-Quadrant [1] 2(c) F 15. Core Exit Temperature

-Quadrant [2] 2 (c) F 16. Core Exit Temperature

-Quadrant [3] 2 (c) F 17. Core Exit Temperature

-Quadrant [4] 2(c) F 18. Emergency Feedwater Flow 2 F c~eijý(a) Not required for isolation valves whose associated penetration is isolated by at least one closed and de activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured. (b) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel. (c) A channel consists of two or more core exit thermocouples.

-REVIEWER'S NOTE Table 3.3.11-1 shall be amended for each unit as necessary to list: 1. All Regulatory Guide 1.97, Type A instruments and 2. All Regulatory Guide 1.97, Category I, non-Type A instruments specified in the unit's Regulatory Guide 1.97, Safety Evaluation Report.Rev. 2, 04/30/01 3.3.11- 3 CEOG STS OpAFrfc PAM Instrumentation (Analog) B 3.3.11 BASES LCO (continued)

8. Containment Isolation Valve Position Containment Isolation Valve Position is provided for verification of containment OPERABILITY.

PCIV position is provided for verification of containment integrity.

In the case of PCIV position, the important information is the isolation status of the containment penetration.

The LCO requires one channel of valve position indication in the control room to be OPERABLE for each active PCIV in a containment penetration flow path, i.e., two total channels of PCIV position indication for a penetration flow path with two active valves. For containment penetrations with only one active PCIV having control room indication, Note (b) requires a single channel of valve position indication to be OPERABLE.

This is sufficient to redundantly verify the isolation status of each isolable penetration via indicated status of the active valve, as applicable, and prior knowledge of passive valve or system boundary status. If a penetration flow path is isolated, position indication for the PCIV(s) in the associated penetration flow path is not needed to determine status. Therefore, the position indication for valves in an isolated penetration flow path is not required to be OPERABLE.

Each penetration is treated separately and each penetration flow path is considered a separate function.

Therefore, separate Condition entry is allowed for each inoperable penetration flow path. [For this unit, the PCIV position PAM instrumentation consists of the following:

] 9. Containment Area Radiation (high range) Containment Area Radiation is provided to monitor for the potential of significant radiation releases and to provide release assessment for use by operators in determining the need to invoke site emergency plans. [For this unit, Containment Area Radiation instrumentation consists of the following:

] 10. tainmen roaen Monitor C anent H-ydro nitr~ts provided to et high,,' ei Rev. 2, 04/30/01 CEOG STS B 3.3.11 -6 PAM Instrumentation (Analog) B 3.3.11 BASES LCO (continued) e"inm reach. variable is also' portant in ver'g the adeq y of miti Ig actions.

[or this u ,Containmen drogen instru ntation consis of the follow' :1 11. Pressurizer Level Pressurizer Level is used to determine whether to terminate safety injection (SI), if still in progress, or to reinitiate SI if it has been stopped. Knowledge of pressurizer water level is also used to verify the plant conditions necessary to establish natural circulation in the RCS and to verify that the plant is maintained in a safe shutdown condition.

[For this unit, Pressurizer Level instrumentation consists of the following:

] 12. Steam Generator Water Level Steam Generator Water Level is provided to monitor operation of decay heat removal via the steam generators.

The Category I indication of steam generator level is the extended startup range level instrumentation.

The extended startup range level covers a span of 6 inches to 394 inches above the lower tubesheet.

The measured differential pressure is displayed in inches of water at 680F. Temperature compensation of this indication is performed manually by the operator.

Redundant monitoring capability is provided by two trains of instrumentation.

The uncompensated level signal is input to the plant computer, a control room indicator, and the [Auxiliary Feedwater (AFW)] Control System. At some plants, operator action is based on the control room indication of Steam Generator Water Level. The RCS response during a design basis small break LOCA is dependent on the break size. For a certain range of break sizes, the boiler condenser mode of heat transfer is necessary to remove decay heat. At these plants, extended startup range level is a Type A variable because the operator must manually raise and control the steam generator level to establish boiler condenser heat transfer.

Operator action is initiated on a loss of subcooled margin. Feedwater flow is increased until the indicated extended startup range level reaches the boiler condenser setpoint.Rev. 2, 04/30/01 CEOG STS B 3.3.11 -7 PAM Instrumentation (Analog) B 3.3.11 BASES ACTIONS (continued)

Completion Time of 7 days is based on the relatively low probability of an event requiring PAM instrumentation operation and the availability of alternate means to obtain the required information.

Continuous operation with two required channels inoperable in a Function is not acceptable because the alternate indications may not fully meet all performance qualification requirements applied to the PAM instrumentation.

Therefore, requiring restoration of one inoperable channel of the Function limits the risk that the PAM Function will be in a degraded condition should an accident occur. D.1 When tw equired h gen monitor c nels are inoperable, uired Actio .1 require nechannel to restored to OPERA status. T Require ion restores monitoring capabilit the hydroge.

onitor. 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Co etion Time is based the relatively Ipf probabi of an event quiring hydrogen m oring and the ilability rnative mea o obtain the requir information.

C Vinuo us s ration with o required channe operable is not eceptable because al mate indications are not available.

E. I This Required Action directs entry into the appropriate Condition referenced in Table 3.3.11-1.

The applicable Condition referenced in the Table is Function dependent.

Each time Required Action C.1 or D.1 is not met, and the associated Completion Time has expired, Condition E is entered for that channel and provides for transfer to the appropriate subsequent Condition.

F.1 and F.2 If the Required Action and associated Completion Time of Condition C are not met, and Table 3.3.11-1 directs entry into Condition F, the plant must be brought to a MODE in which the requirements of this LCO do not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.Rev. 2, 04/30/01 B 3.3.11 -12 CEOG STS PAM Instrumentation (Digital)

B 3.3.11 BASES LCO (continued)

PCIV position is provided for verification of containment integrity.

In the case of PCIV position, the important information is the isolation status of the containment penetration.

The LCO requires one channel of valve position indication in the control room to be OPERABLE for each active PCIV in a containment penetration flow path, i.e., two total channels of PCIV position indication for a penetration flow path with two active valves. For containment penetrations with only one active PCIV having control room indication, Note (b) requires a single channel of valve position indication to be OPERABLE.

This is sufficient to redundantly verify the isolation status of each isolable penetration via indicated status of the active valve, as applicable, and prior knowledge of passive valve or system boundary status. If a penetration flow path is isolated, position indication for the PCIV(s) in the associated penetration flow path is not needed to determine status. Therefore, the position indication for valves in an isolated penetration flow path is not required to be OPERABLE.

Each penetration is treated separately and each penetration flow path is considered a separate function.

Therefore, separate condition entry is allowed for each inoperable penetration flow path. [For this unit, the PCIV position PAM instrumentation consists of the following:

] 9. Containment Area Radiation (high range) Containment Area Radiation is provided to monitor for the potential of significant radiation releases and to provide release assessment for use by operators in determining the need to invoke site emergency plans. [For this unit, Containment Area Radiation instrumentation consists of the following:

Contmnt oen onitors Conta* ent Hydrogen nitors are ided to detect gen concentr n condition at represent a pMntial for ntainment br h This va *le is also import in Rev. 2, 04/30101 CEOG STS B 3.3.11 -6 PAM Instrumentation (Digital)

B 3.3.11 BASES ACTIONS (continued) limits the risk that the PAM Function will be in a degraded condition should an accident occur. Wh two requd hydrogen nitor channel inoperable, 5 red io Arurson nlt ers d to OpE AB status. Th'i Re red Actio the m ring capability e hydroge moni r. The 72 ur Completic me is based on e relatively ability of event requii ydrogen monit ng and theeaýailability of alterna e means to o in the required i rmation .itinuous opera' nwith two re edchannelso rable is no eptable be use alternat ications are not vailable. This Required Action directs entry into the appropriate Condition referenced in Table 3.3.11-1.

The applicable Condition referenced in the Table is Function dependent.

Each time Required Action C.1 or D.1 is not met, and the associated Completion Time has expired, Condition E is entered for that channel and provides for transfer to the appropriate subsequent Condition.

F.1 and F.2 If the Required Action and associated Completion Time of Condition C are not met and Table 3.3.11-1 directs entry into Condition F, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

[G.1 At this plant, alternate means of monitoring Reactor Vessel Water Level and Containment Area Radiation have been developed and tested. These alternate means may be temporarily installed if the normal PAM channel cannot be restored to OPERABLE status within the allotted time. If these alternate means are used, the Required Action is not to shut down the plant, but rather to follow the directions of Specification 5.6.7. The report provided to the NRC should discuss whether the alternate Rev. 2, 04/30/01 CEOG STS B 3.3.11 -12 6 g:Lg74 '6pC

• A95_W,17Z:

ý9-5 Hydrogen Recombiners 3.6.8 3.' CONTAINMENT SYSTEMS 3.LCO 3.6.Hydrogen Recombiners (if permanently installed)

Two hydrogen recombiners shall be OPERABLE.MODES 1 and 2.ACTIONS A. One hydrogen recombiner inoperable.

B. [ Two hydrogen recombiners inoperable.

recombiner to status.30 days 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> AND Every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter 7 days ]3.6.8-1 Rev. 2, STS Hydrogen Recombiners 3.6.8 Jeiete, Rev. 2, 04/30/01 BWOG STS 3.6.8 -2 0 .1, g7, PAM Instrumentation 3.3.17 3.3 INSTRUMENTATION 3.3.17 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.17 APPLICABILITY:

The PAM instrumentation for each Function in Table 3.3.17-1 shall be OPERABLE.

MODES 1, 2, and 3.ACTIONS-NOTES 1. LCO 3.0.4 is not applicable.

2. Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required channel 30 days with one required to OPERABLE status. channel inoperable.

B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A not Specification 5.6.7. met.channels i r One or more Functions with two required channels inoperable.

r D. Two required hydrogen D.1 Res monitor channels hyd inoperable.

to C Restore one channel to OPERABLE status.

tore one required rogen monitor channel )PERABLE status.7 days72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> C.1 Rev. 2, 04/30/01 BWOG STS 3.3.17- 1 PAM Instrumentation 3.3.17 Table 3.3.17-1 (page 1 of 1) Post Accident Monitoring Instrumentation CONDITIONS REFERENCED FROM FUNCTION REQUIRED CHANNELS REQUIRED ACTION C.1 1. Wide Range Neutron Flux 2 F 2. RCS Hot Leg Temperature 2 per loop F 3. RCS Cold Leg Temperature 2 per loop F 4. RCS Pressure (Wide Range) 2 F 5. Reactor Vessel Water Level 2 G 6. Containment Sump Water Level (Wide Range) 2 F 7. Containment Pressure (Wide Range) 2 F 8. Penetration Flow Path Containment Isolation 2 per penet raion flow F Valve Position path aJ( 9. Containment Area Radiation (High Range) 2 G t ain m~d eCo nerir 'atM, ' "- 11. Pressurizer Level 2 F 12. Steam Generator Water Level 2 per SG F 13. Condensate Storage Tank Level 2 F 14. Core Exit Temperature 2 independent sets of 5 (c) F 15. Emergency Feedwater Flow 2 F-REVIEWER'S NOTE Table 3.3.17-1 shall be amended for each unit as necessary to list all U.S. NRC Regulatory Guide 1.97, Type A instruments and all U.S. NRC Regulatory Guide 1.97, Category I, non-Type A instruments in accordance with the unit's U.S. NRC Regulatory Guide 1.97, Safety Evaluation Report. (a) Not required for isolation valves whose associated penetration is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured. (b) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel. (c) The subcooling margin monitor takes the average of the five highest CETs for each of the ICCM trains.Rev. 2, 04/30/01 BWOG STS 3.3.17 -3 0 02A FTýjeleýe PAM Instrumentation B 3.3.17 BASES LCO (continued)

8. Containment Isolation Valve Position PCIV position is provided for verification of containment integrity.

In the case of PCIV position, the important information is the isolation status of the containment penetration.

The LCO requires one channel of valve position indication in the control room to be OPERABLE for each active PCIV in a containment penetration flow path, i.e., two total channels of PCIV position indication for a penetration flow path with two active valves. For containment penetrations with only one active PCIV having control room indication, Note (b) requires a single channel of valve position indication to be OPERABLE.

This is sufficient to redundantly verify the isolation status of each isolable penetration via indicated status of the active valve, as applicable, and prior knowledge of passive valve or system boundary status. If a penetration flow path is isolated, position indication for the PCIV(s) in the associated penetration flow path is not needed to determine status. Therefore, the position indication for valves in an isolated penetration flow path is not required to be OPERABLE.

Each penetration is treated separately and each penetration flow path is considered a separate function.

Therefore, separate Condition entry is allowed for each inoperable penetration flow path. [For this plant, the PCIV position PAM instrumentation consists of the following:

] 9. Containment Area Radiation (High Range) Containment Area Radiation (High Range) instrumentation is provided to monitor the potential for significant radiation releases and to provide release assessment for use by operators in determining the need to invoke site emergency plans. [For this unit, the Containment Area Radiation instrumentation consists of the following:]

[10. ontai ent Hydroe Concentratiag ontainm Hydrogen C entration in mentation is prnvide to detc gh hydrogen ncentration diti~ons that re ennttIfn rntmo hnh h ,rah , r mrrtt Rev. 2, 04/30/01 BWOG STS B 3.3.17 -6 PAM Instrumentation B 3.3.17 BASES ACTIONS (continued)

B.1 Required Action B.1 specifies initiation of action described in Specification 5.6.7, that requires a written report to be submitted to the NRC. This report discusses the results of the root cause evaluation of the inoperability and identifies proposed restorative actions. This action is appropriate in lieu of a shutdown requirement since alternative actions are identified before loss of functional capability and given the likelihood of unit conditions that would require information provided by this instrumentation.

The Completion Time of "Immediately" for Required Action B.1 ensures the requirements of Specification 5.6.7 are initiated.

C.A When one or more Functions have two required channels inoperable (i.e., two channels inoperable in the same Function), one channel in the Function should be restored to OPERABLE status within 7 days. This Condition does not apply to the hydrogen monitor channels.

The Completion Time of 7 days is based on the relatively low probability of an event requiring PAM instrumentation action operation and the availability of alternative means to obtain the required information.

Continuous operation with two required channels inoperable in a Function is not acceptable because the alternate indications may not fully meet all performance of qualification requirements applied to the PAM instrumentation.

Therefore, requiring restoration of one inoperable channel of the Function limits the risk that the PAM Function will be in a degraded condition should an accident occur. he euie oe oito nel re inoppaTýequired Aci 1rqion h e erstored to o9;EAB L'E status.t T action ores the mo o ring capaIlity -e hydrogen m or. he 72 r Completio .ine is based OWe reaiely low bblio 0h e 'relyt bability of an ev t requiring rogen and the availa of alternativq, ns to obtai e required i mation. Contin s operation o required ch nels inopera is not acceptab ecause alter indicatio are not availa6le.

E.1 Required Action E.1 directs entry into the appropriate Condition referenced in Table 3.3.17-1.

The applicable Condition referenced in the Rev. 2, 04/30/01 B 3.3.17 -10 BWOG STS